Privacy Statement
In this Privacy Statement, we have provided information about data collected and used when you:
Purchase a Volkswagen vehicle or otherwise interact with Volkswagen and our Digital Properties, vehicles, products and services
Receive Car-Net® Services (defined below).
If you are the vehicle owner, you must notify any additional drivers about the privacy practices described in this Statement and if you are the Primary Driver for this vehicle’s Car-Net Services, you must notify any additional drivers of the vehicle about the Car-Net specific privacy practices described herein.
Privacy Statement
Effective Date: January 1, 2023
At Volkswagen of America, an operating division of Volkswagen Group of America, Inc., (“VW,” “we,” or “us”), we value your privacy and want you to know how your information will be handled and used. This Privacy Statement applies to information we obtain from and about individuals interacting with VW websites, mobile applications, and other online services (collectively, our “Digital Properties”); VW vehicles, products and services; hardware and software in your VW vehicle that enables you to receive the personal assistance and telematics-based services provided through VW Car-Net (the “Car-Net Services”); and through other online and offline interactions with VW. However, this Statement does not apply to business contacts or VW job applicants or employees. The privacy statement for VW business contacts and job applicants can be found here.
This Statement does not apply to VW Credit, Inc. (“VCI”) or its products, contracts, and related services. VCI has its own privacy statement, which can be found here.
Below we provide a summary of the general information we collect, how we use it, and to whom it is disclosed.
Table of Contents
1. From What Sources Do We Collect Information?
As you interact with VW and its Digital Properties, vehicles, products and services, we may collect certain information from or about you or your vehicle from the following sources:
- Directly from you, such as when you visit or use VW Digital Properties; use third-party digital properties (including social media sites and sweepstakes microsites); during other interactions such as product and related events, test drives, surveys, and promotion entries; and when you interact with our customer call centers.
- Cookies and online technologies, such as when you access or use VW Digital Properties, third-party digital properties (including social media sites and sweepstakes microsites), or VW mobile applications.
- Authorized VW Dealers, such as through leasing, service and other records provided to us by Authorized VW Dealers.
- VW-authorized sellers of consumer merchandise.
- Our affiliates, including VCI (if you finance your VW vehicle purchase or purchase products from VCI) and other companies within the Volkswagen Group family of companies.
- Third party service providers, Integrated Content Providers and Optional Third Parties (defined in Sections 4.7 and 4.8 below).
- Other third parties, such as companies that provide or sell lists of potential vehicle purchasers and current owners, data brokers, business partners, public sources, social media platforms and networks, or other parties that interact with us.
2. What Information Do We Collect?
As you interact with VW and its products and services, we collect different types of information from you based on the interaction, such as when you purchase a vehicle and subscribe to Car-Net services.
The types of information that VW collects about you include:
- Identifiers, characteristics and other information you provide, including contact information; authentication information you create (such as a Volkswagen ID, date of birth, or other information to verify your identity); your preferences, photographs, user-generated content, and other materials that you may submit; demographic information; account and billing information, including financial data used for payment purposes; and profile information and settings (such as your preferences or information about personalized services).
- Commercial information regarding vehicle purchase/lease/service, including contact information (such as name, address, telephone number, email); vehicle purchase, lease or service information (such as VIN, make, model, year, dealer, date of purchase or lease, purchase/lease price, vehicle equipment, and service history); and other purchasing or consuming histories or tendencies.
- Vehicle usage information, such as vehicle data transmitted from your vehicle or collected or inferred from your use of the vehicle or services, including general vehicle status data (such as warning lights, upcoming service schedule, fuel level, battery level, and tire pressure); service history and fault or trouble codes; ambient data (such as outside temperature and brightness); vehicle performance data and other data about your vehicle, including its identification, condition, equipment status, or collision information; vehicle/technology usage data (such as usage of lock/unlock and remote start technology); driver behavior data (such as vehicle speed, seat belt use, and information about braking habits); information that you provide when using Car-Net Services, including information you send and information you request; and information about your interactions with us, our affiliates, our service providers, Integrated Content Providers, and Optional Third Parties related to your vehicle usage.
- Internet and electronic activity information, such as data gathered by tracking technologies when you visit our Digital Properties (as further described in Section 5 below) and information about your use of Car-Net Services, the Car-Net mobile application, and the Car-Net website.
- Geolocation data.
- Audio, electronic, visual, or similar information, such as call recording for emergency and customer service and voice command data (including any personal data included therein) and the transcripts of conversations you engage in with us via webchat, messaging apps, or social media.
- Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences, characteristics, demographics and vehicle usage patterns.
3. How Do We Use Your Information?
We collect and use your information for a number of business purposes, such as:
- To provide you with products and services, such as to provide products and services you request; support your vehicle, products, and services; diagnose, repair, and track service and quality issues; communicate with you about your vehicle, products, or services; install and configure changes and updates to your services; authenticate users of our products and services; verify your eligibility for certain programs or benefits; or to provide you with Car-Net Services.
- For our own internal business purposes, such as to evaluate the usage, performance, and safety of our vehicles, products, and services; improve the quality of our vehicles, products, and services and design new products and services; operate our Digital Properties and customize the content; or to maintain internal records.
- For legal, safety or security reasons, such as to comply with legal requirements; protect the safety, property, or rights of VW and the Volkswagen Group family of companies (such as VCI’s right to repossess its vehicles, including by using GPS data) and those of owners, registered users, drivers, passengers or others; or to prevent and detect fraud or misuse of the vehicles, products, or services.
- For marketing, such as marketing our products or services or those of our affiliates, business partners, or other third parties. However, please note that we will not use or disclose precise GPS location data or your driver behavior data for our own marketing purposes or for the marketing purposes of unaffiliated third parties without your affirmative consent.
- In a de-identified or aggregated format, we may also use or disclose your information in a de-identified or aggregate manner for any purpose.
We also provide your information to third parties who use it for the commercial purpose of marketing their products and services to you.
Please note that for MY19 and older vehicles, we will only use GPS location for purposes of providing Car Net Services to subscribers, complying with legal process, or as otherwise required by law.
7. Our Commitment to Children's Privacy
VW does not knowingly collect, use, disclose, or sell the information of children under the age of 16. In the event that we learn that we have collected information from a child under age 16, we will delete that information. For questions or additional information, please contact us using the information in Section 13 below.
8. External Links
The Digital Properties may contain links to other websites, including social networks, advertisers, VW Dealer websites, VCI websites, other Volkswagen Group websites, other websites operated by VW AG, and websites belonging to other third parties. Some of these sites may share a similar “look and feel” to our Digital Properties. Please be aware that we are not responsible for the privacy practices of other websites. We encourage you to read the privacy statements provided by other websites before you provide information to them.
9. Security and Retention
VW maintains reasonable safeguards to protect your information. Some services, including Car-Net® Services, may involve the transmission of voice and data from your VW vehicle over wireless and cellular telephone networks and therefore, we cannot guarantee the privacy and security of conversations or data transmitted to and from your VW vehicle.
Your information will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your information to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety, and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your information in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts, or for other legitimate business purposes, such as to demonstrate our business practices and contractual obligations or provide you with information about our products and services in case of interest.
10. Changes to this Privacy Statement
From time to time, we may update this Privacy Statement by updating this page and by displaying the date of the last update at the top of the page. We encourage you periodically to check this site to learn about the information we collect, use, and disclose. Your continued use of any of our Digital Properties, products or services affirms your agreement to such changes.
11. DriveView™ and Vehicle Choices
- DriveView™ If you are eligible for and opt-in to DriveView (a usage-based insurance program), VW will collect and use commercial and electronic network activity information collected through Car-Net Services about your driving behavior, such as speed, braking and seat belt usage, and GPS location in order to assess your driving and routinely provide you a DriveView score (i.e. a score based on certain factors that are considered higher indicators of risk of collision, such as hard braking, nighttime driving, idle time and high speed). We will collect this data directly from you and your use of the Car-Net technologies. We also will use aggregated data to conduct driver behavior modeling (for example, comparing drivers across different states). If you opt-in and direct us to do so, we also will send your driver behavior and GPS location data to our insurance company partners for consideration. They may offer discounts depending on your driving record. You can also opt-in to DriveView and direct us to disclose your driving data and GPS location data to your existing insurance carrier. We will provide it only at your direction, but you may discontinue disclosure at any time by un-enrolling in DriveView.
Please visit the Car-Net website for more information about the DriveView program, eligibility requirements and how you can participate. - Vehicle Choices
You can discontinue the Car-Net Services data collection described in this Privacy Statement at any time by unenrolling your vehicle from Car-Net. However, this will result in loss of Car-Net Services. For Model Year 2020 and newer vehicles, you can unenroll from Car-Net via the Car-Net website, Car-Net mobile app or by calling Car-Net Response Center at 1-833-648-2735. For Model Year 2019 and older vehicles, you can unenroll by calling 1-877-820-2290.
Please note that the information stored in your VW vehicle (e.g., phone contacts if you pair your smartphone, points of interest saved through navigation system) may be accessible to others who use your VW vehicle or mobile device, and thus may be deleted, altered, or transferred.
Information stored in your vehicle may also be accessible to a new owner in a private sale of the vehicle. Please consult your Owner’s Manual for instructions on how to perform a factory reset to remove information stored in your vehicle.
12. Your State Privacy Rights
In addition to the details provided above about the information we collect and how we use and disclose it, below is a list of the categories of personal information collected and for each category, the categories of third parties to whom we disclosed it for a business or commercial purpose (as defined under applicable law).
Although we have not "sold" personal information for money in the past 12 months, we disclose information for targeted advertising purposes and in other situations that may constitute a "sale" or “sharing” as defined under applicable law.
Category of Personal Information | Categories of third parties to whom it was disclosed for a business purpose | Categories of third parties to whom it was sold for marketing purposes |
|---|---|---|
Basic identifiers |
|
|
Protected class information |
| Not sold or shared. |
Commercial information |
|
|
Internet activity |
|
|
Geolocation data |
| Not sold or shared. |
Sensory data |
| Not sold or shared. |
Professional or employment-related information |
| Not sold or shared. |
Education information |
| Not sold or shared |
Biometric information |
| Not sold or shared. |
Sensitive personal information |
| Not sold or shared. |
Inferences |
|
|
Categories of third parties to whom it was disclosed for a business purpose
- Within the Volkswagen Group family of companies
- With third-party service providers
- With VW Dealers
- With others for legal, security or safety purposes
- With other companies in connection with a VW corporate transaction
- Integrated Content Providers
- Optional Third Parties
- With other third parties that you direct or provide consent
Categories of third parties to whom it was sold for marketing purposes
- With third-party entities that provide online advertising and analytics functionality
- With third parties for their own marketing purposes, such as Sirius XM, VW Dealers, Verizon and select companies with whom we may partner to offer you products or services.
We only use Sensitive Personal Information for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; and/or (vii) verifying or maintaining the quality or safety of a service or device.
Your State Privacy Rights
Depending on where you live, you may have certain rights, subject to legal limitations, regarding the collection, use, and disclosure of your personal information. You can submit a Data Subject Rights Request by visiting privacy.vwgoa.com and following the instructions in the portal, or by calling (833) 909-1767.
Please note that certain rights may be limited where your personal information is subject to certain state or federal laws, such as the Fair Credit Reporting Act (“FCRA), the federal Gramm-Leach-Bliley Act (“GLBA”), or state law equivalents.
- Right to Opt-Out/Do Not Sell
Depending on where you reside, you may have the right to opt-out of the “sale” or “sharing” of your personal information and/or targeted advertising . In order to fully exercise the Right to Opt-Out of Sale/Sharing/Targeted Advertising, you must undertake both of the following steps:
- Submit an Opt-Out of Sale/Sharing/Targeted Advertising request by going to privacy.vwgoa.com and following the instructions in the portal, or calling (833) 909-1767.
- Disable Sale/Sharing/Targeted Advertising in the Preference Center, which will place a cookie on your browser signaling that you have opted out of such online activities. Please note:
- The opt-out cookie applies only to the Digital Property you are accessing and the browser and device you are using at the time you make the Preference Center selection. You will also need to disable “Sale/Sharing/Targeted Advertising” in the Preference Center from each browser on each device you use, and on each Digital Property you access.
- If you clear cookies on your browser, you will need to disable the “Sale/Sharing/Targeted Advertising” toggle in the Preference Center from that browser again.
- If you have blocked cookies through your browser settings, we will be unable to comply with your Preference Center opt-out request.
To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.
Nevada residents: Please contact us at privacy@vw.com to inquire about your right to opt out of the sale of your personal information. - Right to Delete
You may have the right to request that we delete personal information that we maintain about you. - Right to correct
You may have the right to request that we correct inaccurate personal information that we maintain about you. - Right to Know
You may have the right to request that we disclose personal information that we have about you. You can request that we provide you with the categories of personal information we have about you, and information about how we used and disclosed those categories of information. You may also request that we provide you the specific pieces of personal information that we have about you. - Verification
In order to verify your identity, match you to our records, and reduce fraud, we will ask you for your personal information or information about you. We also use third party verification companies to help us verify your identify. You will need to provide certain pieces of information to enable us to verify your identity. In order for us to process your request, the information you provide must match our records in a manner that we have determined to be reliable. We may also ask you to provide a declaration, signed under penalty of perjury, certifying that you are the person whose personal information is the subject of the request. - Use of authorized agent
Authorized agents may exercise rights on behalf of consumers by calling 844-987-2272. We will require agents to provide written authorization from the consumer along with completing any other verification requirements described above. - Timing of Response
We will process Requests to Opt-Out of Sale or Sharing within 15 business days. We will respond to all other Data Subject Rights Requests within 45 calendar days, unless we need more time (up to 90 days total), in which case we will notify you.
In accordance with applicable law, we will not discriminate against you for exercising your privacy rights. - Appeals
If we deny your rights request, you may have the right to appeal. To submit an appeal, you may contact us at 844-987-2272.
13. Contact
Should you have other questions or concerns about this Privacy Statement, please email us at: privacy@vw.com.
You may contact us 24 hours a day, at: 1-800-822-8987.
And by mail at:
Office of General Counsel
Volkswagen Group of America
Attn: Privacy Office
2200 Woodland Pointe Avenue
Herndon, VA 20171